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§ 707(b)(2)(A)

DeHart v. Boyd (In re Boyd)

Ruling
Plan expenses for recreation and adult daughter's education disallowed.
Procedural posture

Movant chapter 13 trustee filed an objection to a plan filed by respondent debtors, alleging that the amounts claimed to educate their adult daughter and for their own recreation were over-reaching and should be disallowed under 11 U.S.C. § 707(b)(2)(A).

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Consumer opinion summary, case decided on November 06, 2007 , LexisNexis #0108-078

In re Hale

Ruling
Correction of debtors' overstatement of tax liability resulted in dismissal pursuant to presumption of abuse.
Procedural posture

Debtors, a husband and wife, filed a joint petition for relief under chapter 7, listing primarily consumer debts. The United States Trustee ("UST") filed a motion to dismiss the debtors'action, pursuant to 11 U.S.C. § 707(b)(2) and (3), claiming that the debtors were ineligible for relief under chapter 7.

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Consumer opinion summary, case decided on October 10, 2007 , LexisNexis #1107-083

In re McDevitt

Ruling
Above median debtors' proposed amended plan confirmed over creditor's objection to deductions for secured debt payments on residence and boat.
Procedural posture

The debtors filed for relief under chapter 13 and filed an amended chapter 13 plan. The general unsecured creditor objected to the debtor's proposed amended plan, alleging that the plan did not commit all projected disposable income to the unsecured creditors. The creditor claimed the plan violated 11 U.S.C. § 707(b)(2)(A)(ii)(I), a requisite for confirmation under 11 U.S.C. § 1325(b)(3).

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Consumer opinion summary, case decided on August 28, 2007 , LexisNexis #1007-052

In re Morgan

Ruling
Above-median debtor could take mortgage-rent expense on Form B22C despite being rent- free.
Procedural posture

After debtor deducted the "Local Standard" amount established by the IRS on account of mortgage/rent expense and referenced in 11 U.S.C. § 707(b)(2)(A)(ii)(I), the trustee objected to confirmation on the ground that no deduction was properly taken because debtor was living rent-free. At issue was the proper reading of section 707 as enacted in the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 ("BAPCPA").

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opinion summary, case decided on August 08, 2007 , LexisNexis #0907-086

In re Wilson

Ruling
Above-median debtors could dedcut ownership expsenses on Form B22C for vehicles owned free and clear.
Procedural posture

A chapter 13 trustee filed a timely objection to confirmation of the plan proposed by debtors, a married couple who had filed a chapter 13 proceeding and who were "above- median" debtors for purposes of 11 U.S.C. § 707(b)(2)(A)(ii)(I). At issue was whether debtors were entitled to deduct certain standard vehicle ownership expenses on Official Bankr. Form B22C despite the fact that debtors owned both vehicles free and clear.

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opinion summary, case decided on July 30, 2007 , LexisNexis #0807-120

In re Benedetti

Ruling
Debtor allowed to deduct payments on property intended for surrender in means test calculation.
Procedural posture

Chapter 7 debtor was a single woman who listed two leased vehicles on the date of her petition but subsequently surrendered one of the vehicles. The United States Trustee moved to dismiss the chapter 7 case as presumptively abusive pursuant to 11 U.S.C. § 707(b)(2).

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opinion summary, case decided on July 13, 2007 , LexisNexis #0907-010

In re Edmondson

Ruling
Mortgage payment on rental property which debtor planned to surrender could not be included in calculation of projected disposable income.
Procedural posture

The debtors moved for confirmation of their chapter 13 plan. Creditor filed an objection.

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opinion summary, case decided on July 11, 2007 , LexisNexis #0907-050

In re Kelvie

Ruling
Debtor could claim deductions for secured debt payments on house and motor home despite intent to surrender.
Procedural posture

The United States Trustee filed a motion to dismiss chapter 7 debtors'case under 11 U.S.C. § 707(b).

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opinion summary, case decided on July 10, 2007 , LexisNexis #0807-051

In re Barrett

Ruling
Above-median debtor could claim ownership expense for motorcycle owned free and clear.
Procedural posture

The trustee in bankruptcy objected to the confirmation of the proposed plan of a single, above-median income, chapter 13 debtor, who claimed an ownership expense for two motor vehicles on form B22C, arguing the debtor had not applied all of her "projected disposable income" to make payments to unsecured creditors under her plan as required by 11 U.S.C. § 1325(b).

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opinion summary, case decided on July 10, 2007 , LexisNexis #0907-051

In re Barrett

Ruling
Debtor could claim housing and vehicle deduction in excess of actual expenditures.
Procedural posture

Chapter 13 creditor objected to confirmation of the debtor's plan under 11 U.S.C. § 1325(b)(2) on the grounds that the plan did not apply all of the debtor's projected disposable income to payments to unsecured creditors.

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opinion summary, case decided on July 10, 2007 , LexisNexis #0907-011